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NORTHWEST COALITION FOR ALTERNATIVES TO PESTICIDES/NCAP

P. O. B O X 1 3 9 3, E U G E N E, O R E G O N 9 7 4 4 0 / ( 5 4 1 ) 3 4 4 - 5 0 4 4
JOURNAL OF PESTICIDE REFORM/ SUMMER 1997 VOL. 17, NO. 2
G N E W S F R O M N C A P
HIDDEN TOXIC INERTS:
A TRAGICOMEDY OF ERRORS
Holly Knight is an NCAP intern and just com-
pleted her masters degree in environmental studies
at the University of Oregon. Her work with inerts is
the final project for her degree.
Government regulators divide the
world of pesticide ingredients into two
categories: active and inert. Each
component is regulated differently. Ac-
tive ingredients must be listed on the la-
bel, but the identities of inerts can be
kept secret. Actives are subject to a range
of tests to determine toxicity, while inerts
are hardly tested.
Unfortunately, these distinctions be-
tween pesticide ingredients prove to be
somewhat arbitrary. The low priority
given inerts belies the threats they pose
to the environment and public health.
The story of the U.S Environmental Pro-
tection Agencys (EPAs) failure to pro-
tect the public from toxic inerts, much
less inform them of their exposure, must
be told.
Active Inerts
The Federal Insecticide, Fungicide and
Rodenticide Act (FIFRA), our national
pesticide law, defines an inert as any in-
gredient in a pesticide product which is
not the active ingredient.
1
Active ingre-
dients are defined as chemicals which
prevent, destroy, repel, or mitigate any
pest.
2
They have lead roles, while inert
ingredients are cast in supporting ones.
For instance, inert surfactants break down
the waxy coating on leaf surfaces and help
actives penetrate it.
The seemingly clear-cut nature of these
roles is undermined by the fact that ac-
tive ingredients can be and are used as
inert ingredients. Active inerts refers to
this class of chemicals. How many are
there? In order to answer this question,
EPAs Chemical Ingredients Database for
active ingredients was accessed on the
World Wide Web.
3
Using the most re-
cent list of inert ingredients (May 1995),
Chemical Abstract Service numbers for
each of the 2,518 inerts were entered into
the database.
At least 382 chemicals, 15 percent of
the whole inerts list, are or were regis-
tered as active ingredients; 116 have cur-
rent registrations. That this many active
ingredients can be used legally in pesti-
cide products without being disclosed on
the label constitutes a major oversight by
EPA.
Inerts of Ignored Toxicity
Here, the curtain rises to expose the
failed attempts of EPA to regulate all toxic
inerts. In 1987, EPA unveiled its inerts
strategy designed to reduce the poten-
tial for adverse effects from the use of
pesticide products containing toxic inert
ingredients.
4
Central to the strategy was
the creation of four toxicity categories.
Carcinogens, teratogens, and neurotox-
ins were placed on List 1: Inerts of Toxi-
cological Concern. EPA stipulated that
no new products could use these toxic
inerts and that their presence had to be
disclosed, with a warning statement, on
labels of existing products.
Chemicals that were structurally simi-
lar to List 1 inerts and/or that had in-
complete data sets were placed on List 2:
Potentially Toxic/High Priority for Test-
ing. Inerts of unknown toxicity were
placed on List 3 and inerts generally re-
garded as innocuous were placed on List
4. None of the inerts on these three lists
is disclosed on the label.
Active inerts, ones for which health
and safety data should be fairly com-
plete, provide a startling indictment of
EPAs inerts strategy. Only one active
inert must be disclosed on the label be-
cause it is on List 1. List 2s cast of
characters include neurological and re-
productive toxins, as well as ozone de-
pleting chemicals, many of which have
been on this list since 1987.
Most active inerts reside on List 3:
Inerts of Unknown Toxicity. The total:
264 out of 382 active inerts or 70 per-
cent of the list. Especially egregious ex-
amples of List 3 active inerts include
naphthalene (a common component of
mothballs that can cause brain damage,
convulsions, and death in children
5
),
chlorothalonil (a probable carcinogen, ac-
cording to the Health Effects Division in
EPAs Office of Pesticide Programs
6
), and
chloropicrin (a respiratory tract irritant
that can cause asthma, pulmonary edema,
bronchopneumonia, and death
7
).
That active ingredients are used as
inerts at all calls into question the valid-
ity of EPAs inerts strategy. That only
one active inert must be disclosed on the
label while the rest retain anonymity un-
dermines confidence in EPAs ability to
assess the toxicity of inerts in a timely
fashion.
Malignant Neglect
The plot thickens as we turn our at-
tention to inerts that have long waited in
the wings to be assessed as hazardous by
EPA and assigned List 1 status.
Examples of Active Inerts
acetone
asphalt
benzaldehyde
2-benzyl-4-chlorophenol
chlorine dioxide
5-chloro-2-methyl isothiazolone
chloropicrin
chlorothalonil
coal tar
copper naphthenate
cresol
dazomet
dichlorobenzene
dichlorodifluoromethane
ethoxylated isooctylphenol
methyl naphthalene
naphthalene
polyoxyethylene nonylphenol
propyl p-hydroxybenzoate
salicylic acid
sodium fluoride
solvent naptha
sodium salt of phenylphenol
toluene
xylenes
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NORTHWEST COALITION FOR ALTERNATIVES TO PESTICIDES/NCAP
P. O. B O X 1 3 9 3, E U G E N E, O R E G O N 9 7 4 4 0 / ( 5 4 1 ) 3 4 4 - 5 0 4 4
JOURNAL OF PESTICIDE REFORM/ SUMMER 1997 VOL. 17, NO. 2
For example, butylated hydroxyanisole
(BHA) was classified a possible carcino-
gen by the International Agency for Re-
search on Cancer (IARC) in 1987.
6
Ac-
cording to EPAs own criteria, chemicals
that have been assessed as known, prob-
able, or possible carcinogens by IARC
qualify for List 1.
4
However, BHA hides
among the 1,981 inerts on List 3: Inerts
of Unknown Toxicity. This discrepancy
is particularly troubling because BHA is
a commonly used antioxidant in butter,
vegetable oils, cereals, baked goods, po-
tato chips, meat products, and many other
foods. How much longer does EPA need
to assess BHA as toxic? When will they
require it to be listed on the label with a
warning statement and prohibit new prod-
ucts from containing it?
In 1997, IARC classified two com-
monly used inerts as known carcinogens:
crystalline quartz silica and cristobalite.
9
Neither one of them has to be listed on
the label, and crystalline quartz silica can
be found in at least 1,560 products as an
inert.
10
Their designation as carcinogenic
by IARC is recent, but EPA must not
delay in its redesignation.
Many federal, state, and local agencies
compile lists of hazardous chemicals that
include inert ingredients. For instance, at
least 75 inert ingredients must be reported
under the Superfund Amendments and
Reauthorization Act of 1986 and at least
140 inerts are included on the Occupational
Safety and Health Administrations list of
hazardous substances. Most of these
chemicals are found on EPAs List 3:
Inerts of Unknown Toxicity.
How many more hazardous inerts lurk
in pesticide products? Under the current
strategy of limited testing for inert ingre-
dients, we may never know.
Rewriting the Inerts Script
Thus far, reviews of EPAs perfor-
mance are not good. Actives are used as
inerts. Too many toxic inerts remain un-
disclosed on the label and too many inerts
remain unassessed as to their toxicity. It
could be a comedy of errors if the results
were not potentially tragic. Its time to
send the inerts strategy back for a rewrite.
First, all ingredients must be disclosed
on the label, regardless of toxicity. Wait-
ing to assess an inert as toxic in order for
it to be disclosed on the label is too pro-
tracted a process. Meanwhile, the general
public is being exposed to toxic inerts
without their informed consent. Next, all
chemicals used in pesticides must be sub-
ject to the same health and safety testing
requirements. By law, EPA must disclose
the identities of pesticide ingredients that
pose an unreasonable risk of injury to
health or the environment
11
However,
EPA cannot determine whether a chemi-
cal poses such a risk when it has little or
no information about its toxicity.
By fall of 1997, a more detailed re-
port of the findings presented in this
article will be released. Stay tuned.
Holly Knight
1. FIFRA Sec. 2(m).
2. FIFRA Sec. 2(a).
3. http://www.cdpr.ca.gov/docs/epa/epamenu.htm
4 . U.S. EPA. 1987. Inert ingredients in pesticide
product s; Pol i cy st at ement . Fed. Reg.
52(77):13305-13307. (Apr. 22.)
5. U.S. Dept. of Health and Human Services. Pub-
lic Health Service. Agency for Toxic Substances
and Disease Registry. 1995. Toxicological pro-
file for naphthalene. (Update). (Aug.)
6. U.S. EPA. 1997. Office of Pesticide Programs
list of chemicals evaluated for carcinogenic po-
tential. Memo From W.L. Burnam, Health Ef-
fects Division, to Health Effects Division Branch
Chiefs, et al. Washington, D.C. (February 19.)
7. Clayton, G. D. and F. E. Clayton, eds. 1981. Pattys
Industrial Hygiene and Toxicology (3rd ed.). New
York: Wiley and Sons. Pp. 2242-2247.
8. International Agency for Research on Cancer.
1987. IARC Monographs. Volume 40, Supple-
ment 7. Lyon, France: IARC.
9. International Agency for Research on Cancer.
1997. IARC Monographs. Volume 68. Lyon,
France: IARC.
10. U.S. EPA. Office of Prevention, Pesticides and
Toxic Substances. Office of Pesticide Pro-
grams. Public Information and Records Integ-
rity Branch. Letter from Calvin Furlow in re-
sponse to FOIA RIN-1214-97. May 7, 1997.
11. FIFRA Sec. 10(d)(1).
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